Interpretation ID: aiam1172
Silber
Pickus & Williams
1505 Investment Plaza
Cleveland
OH 44114;
Dear Mr. Kincaid: This is in response to your June 19, 1973, request for samples of th odometer disclosure form described in Part 580, *Odometer Disclosure Requirements*, 49 CFR S 580.6, and for the correct sequence in which to execute the mileage statement and the transfer of ownership.; The Act requires disclosure of odometer readings, but the regulation issued do not require the use of a federally-printed form, and the government therefore does not provide such forms. The use of a commercially-prepared form is satisfactory if it contains the required information, as it appears in the sample format of S 580.6. The document does not have to be separate from other transfer documents, and in the case of a transferor using a bill of sale or other transfer document, the statement may be included within the form. Either the original or a carbon copy may be given to the transferee.; Section 580.4(a) requires a transferor to furnish the statement 'Befor executing any transfer or ownership document' and include the odometer reading at the time of transfer and the date of transfer. To accomplish this, the statement must precede the transfer and should be executed on the date of transfer to reflect an accurate mileage and date. The date of the statement would then function as the date of transfer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel